Zorn v. Linton · ¶9

The Second Circuit reversed. It held that its decision in Amnesty America v. West Hartford, 361 F. 3d 113 (2004), clearly established that the “gratuitous” use of a rear wrist- lock on a protester passively resisting arrest constitutes excessive force. 135 F. 4th 19, 35 (2025). It remanded for a jury trial against Zorn. Judge Cabranes dissented. “The case before us is not an exceptional case,” Judge Cabranes reasoned, but “a routine arrest and removal.” Id., at 41.

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